UPDATE: EPA Proposed Changes to Air Emissions Reporting Requirements

October 18, 2023

USEPA published its proposed revisions to Air Emissions Reporting Requirements (AERR) in August. AERR is a regulation that requires states, local agencies, and some tribes (SLTs) to report annual air emissions to EPA. The comment period has been extended until November, 17, 2023.

EPA is holding a webinar on the proposed rule on October 25, 2023, from 2 pm to 5pm (Eastern Time).

The current regulation allows voluntary reporting of air toxics emissions. EPA uses the data collected and other resources to create the National Emissions Inventory (NEI). NEI supports programs and activities such as Modeling (Air Quality Standards, Risk Analysis, etc.), Trends (Air Quality Trends Report), and Public Information.

AERR currently requires reporting of:

1. Criteria Air Pollutants (CAP – CO, SO2, PM10, PM2.5 and Lead).
2. Precursors (VOC and NOx for Ozone and Ammonia for PM).
3. Point source emissions must be reported as emissions within the facility.
4. States report other emissions (residential wood combustion and mobile sources) as county-wide emission totals.
5. CAP emissions report to SLTs, and SLTs report to EPA. SLTs also accept optional HAP reporting responsibility.

Proposed AERR revisions:

1. No changes to CAP emissions reporting (i.e., SLTs report to EPA).
2. Source test data and Hazardous Air Pollutants to report directly to EPA.
3. Major sources to report all Hazardous Air Pollutants to EPA.
4. Non-major sources with listed industry codes and > HAP thresholds to report HAPs to EPA.
5. Report all point sources every year, starting with 2026 in the year 2027.
6. Report geographic coordinates of release points for point sources.
7. Include emissions from mobile sources operating within the facility.
8. Reporting of Title V Operating Permit Number is required.
9. Report emissions from Small Generating Units: boilers, turbines, IC engines, or other units combusting fuel to generate electricity for grid or on-site use (other than emergency use).
10. Emission data will no longer qualify as confidential information.

Proposed Phase-in of Stationary Point Source Reporting for owners and operators:

1. For years 2026-2029 – 5 months from the end of the inventory year.
2. For the years 2030 and beyond – 3 months from the end of the inventory year.
3. Owners/Operators must report to EPA using CARES – Combined Air Reporting System.

Comments due:

1. November 17, 2023. Send comments via regulations.gov docket ID EPA-HQ-OAR-2004-0489.
2. Find additional information on the proposed rule here.
3. EPA is holding a webinar on the proposed rule on October 25, 2023, from 2 pm to 5pm (Eastern Time).

Please direct questions about your facility to your SCS project manager or .